722.pdf
- Type
- pdf
- Source set
- house-oversight-doj
- Pages
- 7
- Text status
- Searchable text available
- OCR confidence
- 0.9228036320933348
Original source
Extracted text
Case 1:20-cr-00330-PAE Document 722 Filed 07/12/22 Pagelof7 Haddon, Morgan and Foreman, P.C Jeffrey S. Pagliuca My 150 East 10th Avenue Denver, Colorado 80203 PH 303.831.7364 FX 303.832.2628 www.hmflaw.com [email protected] HADDON MORGAN FOREMAN December 15, 2021 VIA Email The Honorable Alison J. Nathan United States District Court Southern District of New York 40 Foley Square New York, NY 10007 Re: — United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan, I write to alert the Court and the government to the inconsistent statements Ms. Maxwell intends to prove up by extrinsic evidence during her case. Ms. Maxwell conferred with the government about this issue. After conferral, and given the press of time, counsel concluded it was most efficient to provide this notice to the Court and the government and to allow the government to consider which other statements it would stipulate to in addition to those the parties have already agreed on. A. Jane Inconsistent Statements Trial Testimony | 3500 material cite 3500 quote 375:20 —376:20 | 3509-008, p. 12, 4" From when Jane met Epstein to when she moved paragraph, last sentence | to New York she lived in the same house in Florida. This house was in a gated community called Bear Lakes. It was a 3 bedroom house. 447:2 — 447:20 3509-002, p. 1 GM walked by w/ dog. JE came up to meet her. DOJ-OGR-00011356
Case 1:20-cr-00330-PAE Document 722 Filed 07/12/22 Page2of7 The Honorable Alison J. Nathan December 15, 2021 Page 2 448:12 — 15 3509-007, p. 3, para. 13 | Doe was sitting alone on a bench between classes when Epstein and Maxwell approached her. 450:21 —451:15 | 3509-028, p. 1 At first tea w/ Epstein, just Epstein, Mom & Jane were present. 451:4 — 452:21 3509-001, p. 2, 4 para. | In the beginning, Jane would be with her mother and brothers at Epstein’s house. 453:15 — 454:3 3509-003, p. 1, 4 para. | Jane was not sure if Maxwell ever called her to make appointments. 454:4 —9 3509-00…
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